Christopher

No need to repeat 100% dielectric strength testing for Japan <PSE> . You must 
provide the importer test records showing test has been performed on 100% 
production. The importer must retain these records for METI inspection.

Peter

Sent from my iPhone

Peter S. Merguerian
[email protected]
Go Global Compliance Inc.
www.goglobalcompliance.com
(408) 931-3303

On Apr 29, 2013, at 4:02 PM, Chris <[email protected]> wrote:

>  
> Carl,
>  
> you not alone dealing with such issues.
>  
> Similar rules also apply to the PSE marketed wall-wort power supply in Japan.
> We are also facing 100% dielectric voltage withstand testing be repeated on 
> all in coming power supplies
> Our porduct is a WiFi a/b/g/n device.
> I guess the Denon Law prevails and Meti is the agency that is responsible.
>  
> This process adds cost to our 12Vdc power supply.
> Labor in Japan is not cheap.
>  
> Christopher
> From: Carl Newton <[email protected]>
> To: [email protected] 
> Sent: Monday, April 29, 2013 11:54 AM
> Subject: NRTL requiring duplicate testing
> Customer has a medical wall-wort power supply that has the typical NRTL (call 
> them NRTL1) safety mark that you’d expect to see on a power supply marketed 
> within the USA.  Customer’s entire device is located within the secondary of 
> that wall-wort power supply and includes no connections to other mains 
> connected devices. 
>  
> Now another one of the large well-known NRTLs (I’ll call them NRTL2) which is 
> handling the AAMI 60601-1 project for customer’s end product is requiring 
> that 100% dielectric voltage withstand testing be repeated on the power 
> supplies.  The power supply manufacturer has provided sections of their NRTL1 
> File that details the requirement for 100% testing of their supply in 
> manufacturing as well as the voltage amplitude and duration required.  Still, 
> customer’s NRTL2 is demanding that this test be repeated upon 100% of the 
> power supplies at customer’s premises.  It appears that I have no choice but 
> to agree to repeat the additional testing.  This adds cost to manufacturing 
> and flies in the face of great efforts on the part of American manufacturers 
> that try to keep their operations within the USA by maximizing productivity.  
> I’ve worked on many other projects with wall-wort and external brick power 
> supplies with other NRTLs and this has never been a requirement.
>  
> I try to keep an open mind even when I’m disagreed with.  But I think that 
> this is the first time in my 30ish years of compliance work that I’ve seen 
> engineering judgment completely thrown out the window.  I’m interested in 
> other points of view.
>  
> Carl
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> 
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